If you are a trustee of a family trust, an executor of an estate, or a family member holding property on behalf of someone else, the trust's year end starts a 90-day clock. This checklist lists what I ask trustees to gather, the key dates for a December 31, 2026 year end, and the points that change for 2026, including bare trusts. Each rule links to the CRA page or cites the Income Tax Act section so you can confirm it. It is general information, not advice for your situation.
Key dates for a December 31, 2026 year end
- December 31, 2026: year end for most trusts. Trusts other than a graduated rate estate (GRE) and certain mutual fund trusts generally must use a December 31 tax year end. (CRA guide T4013, T3 Trust Guide)
- Wednesday, March 31, 2027: the T3 return, the T3 slips to beneficiaries, the T3 Summary, Schedule 15 where it applies, and any balance owing. The CRA's rule is no later than 90 days after the trust's tax year end. (CRA guide T4013; Income Tax Act, para. 150(1)(c))
- Counting the 90 days: for a December 31 year end, day 90 is March 31 in a normal year and March 30 when the following year is a leap year. For example, a December 31, 2027 year end is due March 30, 2028. If the due date falls on a Saturday, Sunday, or public holiday recognized by the CRA, a return received or postmarked by the next business day is on time, and a payment received or processed at a Canadian financial institution by the next business day is on time. (CRA guide T4013)
- Other year ends: a GRE can have a non-calendar year end. Count 90 days from its own year end. You can check a date with my CRA deadlines tool, which includes a T3 date finder.
1. Confirm that the trust must file
- A trust resident in Canada that is an express trust must file a T3 return every year, unless it is a "listed trust". Many trusts that did not file in the past now have to file even with little or no income. (CRA: enhanced reporting rules for trusts and bare trusts, FAQ, question 2.1; Income Tax Act, s. 150(1.2) and (1.3))
- Other trusts, including listed trusts, still file in certain situations, for example when the trust has tax payable, disposes of capital property, or allocates income to beneficiaries and meets set thresholds, such as total income over $500, more than $100 of income allocated to one beneficiary, or a capital distribution. The CRA FAQ lists the situations. (CRA FAQ, question 2.1)
- The 2025 edition of CRA guide T4013 also describes proposed changes under which, for taxation years ending on or after December 31, 2025, certain trusts may not need to file a T3 return if specific conditions are met. Proposed changes are not law until enacted, so I confirm the status before relying on them.
- If the trust is new, it needs a trust account number before the first return. Allow time for this in the first year.
2. Bare trusts: what changes for 2026
- Years ending in 2024 or 2025: the CRA states that bare trusts are not required to file a T3 return, including Schedule 15, for taxation years ending in 2024 or 2025. For 2023, it did not expect bare trusts to file unless it made a direct request. (CRA FAQ)
- Years ending on or after December 31, 2026: certain "reportable bare trusts" may need to file a T3 return and Schedule 15, unless an exception applies. A reportable bare trust is, in general terms, an express arrangement where a legal owner holds property for the use or benefit of one or more persons and can reasonably be considered to act as their agent. (CRA FAQ, questions 1.3.D and 3.1; Income Tax Act, s. 150(1.3) and (1.31))
- Exceptions the CRA describes include, among others: every beneficiary is also a legal owner and every legal owner is a beneficiary (for example, a joint bank account of family members); related individuals on title to a home that would be the principal residence of one or more of them (for example, a parent on title so a child can get a mortgage); one spouse on title to a home the couple lives in; a partner holding property for a partnership that files a partnership information return; and property held as required by a court order. Each exception has conditions, so read the CRA wording or ask before you rely on one. (CRA FAQ, question 3.1)
- Where a reportable bare trust files, the CRA says only the marked lines of the T3 return need to be completed, and the income from the property is reported by the beneficial owner on their own return.
- If you are on title to property or hold an account for someone else, list those arrangements now, so we can review them before March 31, 2027.
3. Documents to gather
- The trust deed or will, and any amendments, letters of wishes, or court orders
- Names, addresses, dates of birth, countries of residence, and SINs or other tax numbers for every trustee, settlor, beneficiary, and controlling person (needed for Schedule 15)
- The trust account number, and the prior year's T3 return and notice of assessment
- Year-end bank and investment statements, and the T3, T5, T5008, and other slips the trust received
- Records of property bought or sold in the year, with cost and proceeds, and any real estate or private company shares the trust holds
- Trustee resolutions and records of amounts paid or made payable to beneficiaries in the year, with dates
- Expense records, such as trustee fees, investment counsel fees, and accounting fees
- Any loans to or from the trust, and gifts of property into the trust in the year
- For an estate: the date of death, the deceased's final T1 return, and a list of assets at death and of distributions made
You can send these through my secure upload page rather than by regular email.
4. Income allocation and T3 slips
- Income paid or made payable to a beneficiary in the year can be deducted by the trust and taxed in the beneficiary's hands. An amount is payable only if the beneficiary was entitled in the year to enforce payment. Trustee resolutions should be in place by December 31. (Income Tax Act, s. 104(6) and 104(24))
- T3 slips report each beneficiary's share. They must be sent to the beneficiary's last known address no later than 90 days after the trust's year end, the same day as the return. (CRA guide T4013, chapter 4; Income Tax Regulations, s. 204)
- Check whether the trust reaches a 21-year anniversary in the year. Most trusts are deemed to dispose of their capital property every 21 years, which can create tax even without a sale. (Income Tax Act, s. 104(4); CRA guide T4013, Form T1055)
5. Schedule 15 (beneficial ownership)
- Trusts that must file a T3 return, other than listed trusts, generally include Schedule 15 with the name, address, date of birth (for individuals), country of residence, and tax identification number of each trustee, settlor, beneficiary, and controlling person. (CRA FAQ, question 1.4)
- The CRA treats a schedule with missing information, such as a missing tax number, as incomplete, which means the filing obligation is not met. Collect the numbers early.
6. Balance owing and penalties
- Pay any balance owing no later than 90 days after the year end. Interest is charged on amounts paid late. (CRA guide T4013)
- The late filing penalty is 5% of the unpaid tax on the due date, plus 1% for each full month late, up to 12 months. (Income Tax Act, s. 162(1); CRA guide T4013)
- Where a trust files late and has no unpaid tax, the CRA describes a penalty of $25 a day, from $100 to $2,500. A separate penalty for knowingly or grossly negligent failures is the greater of $2,500 and 5% of the highest fair market value of the trust's property in the year. (CRA FAQ; Income Tax Act, s. 162(7), 163(5), and 163(6))
7. Estates and graduated rate estates
- A GRE can choose a non-calendar year end. It stops being a GRE no later than 36 months after the date of death, which creates a deemed year end, and later years are generally calendar years. (CRA guide T4013)
- When a GRE makes its final distribution, its year ends on that date, and the final T3 return and balance owing are due 90 days later. (CRA guide T4013)
- Before distributing all the property, executors often ask the CRA for a clearance certificate with Form TX19, so they are not personally liable for unpaid tax.
- Certain capital losses of a GRE can be carried back to the deceased's final return. Under proposed changes described in CRA guide T4013, for deaths on or after August 12, 2024, this election can cover losses from the first three taxation years of the GRE, instead of only the first. (Income Tax Act, s. 164(6); CRA guide T4013)
Trustee year-end checklist
- Confirm whether the trust must file for 2026, including any bare trust arrangements
- Resolutions for amounts paid or payable to beneficiaries signed by December 31
- Trust deed, prior T3 return, and notice of assessment on hand
- Bank and investment statements, and slips the trust received
- Purchases and sales of property, with cost and proceeds
- Names, addresses, dates of birth, countries of residence, and tax numbers for Schedule 15
- 21-year anniversary checked
- T3 return, T3 slips, T3 Summary, and balance owing by Wednesday, March 31, 2027
Next step
If you would like me to prepare the trust's T3 return and slips, or to review whether an arrangement is a reportable bare trust, book a call. My trust tax (T3) services page explains what is included. The fee estimator lists T3 returns as quoted separately, because the work depends on the trust.
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Sources
- CRA guide T4013, T3 Trust Guide
- CRA: Enhanced reporting rules for trusts and bare trusts, frequently asked questions
- CRA tax tip: Important updates to the trust reporting requirements
- Income Tax Act, s. 104(4), 104(6), 104(24), 150(1)(c), 150(1.2), 150(1.3), 150(1.31), 162(1), 162(7), 163(5), 163(6), and 164(6); Income Tax Regulations, s. 204
This guide is general information based on the CRA pages listed above, checked on October 27, 2026. It does not replace advice for your situation. Trust rules, and the bare trust rules in particular, have changed several times; check the linked pages or ask me before you act.